Jurisdiction(s):
United Kingdom

Applying the FCA Consumer Duty to Outsourcing: Scope, Governance, Service Levels, Remediation and Exit for UK Authorised Firms

Published by a LexisNexis Financial Services expert

Practice notes

This Practice Note explores how the Financial Conduct Authority (FCA) Consumer Duty affects FCA‑authorised firms’ outsourced service arrangements and their operational systems and controls. It also outlines practical points for firms to consider when reviewing in‑scope material outsourcing agreements for compliance with the Duty.

The Consumer Duty applies to all regulated firms that materially influence, or determine, retail customer outcomes.

For the core elements of the FCA’s Consumer Duty, see Practice Note: The FCA Consumer Duty—essentials. For requirements on manufacturers and distributors to share information within the distribution chain and with the FCA under the Duty, see Checklist: The FCA Consumer Duty Checklist—information sharing in the distribution chain. Good and poor practice concerning third parties is covered in The FCA Consumer Duty Checklist—implementation—Third parties (working across the manufacturing and the distribution chain). For key developments, see The FCA Consumer Duty—timeline. For practical outsourcing guidance, see Practice Note: Financial services outsourcing.

Key points

Key points on the implications of the Consumer Duty for outsourcing are as follows:

the Consumer Duty applies even where a firm does...

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Angela Greenough

CMS

Angela heads a team with a unique offering for clients specialising in outsourcings by financial institutions. She is recognised as a leading financial services individual in Legal 500 for combining both commercial and regulatory expertise in complex outsourcings and commercial contracts.Angela advises on the operational aspects of financial services regulation such as Operational Resilience and third party risk management....

Joy Davey

CMS

• I specialise in outsourcings by financial institutions. I combine both commercial and regulatory expertise when helping clients negotiate their outsourcing arrangements.• This includes advising clients on applicable outsourcing requirements (including SYSC 8 and the EBA Guidelines), their cloud outsourcing arrangements, the operational resilience requirements (SYSC 15A) and the interaction with DORA in the UK. • I help clients navigate the operational aspects of financial services regulation.• I co-founded Women Who Work which supports and encourages women back to work whilst having children....

Web page updated on 21/05/2026

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